HazCom Labeling and Global Harmonization

Classification, labeling, and Safety Data Sheets will never be the same again. You must now comply with the new OSHA hazardous chemical labeling requirements.

As of May 2012, OSHA’s hazardous chemical labeling requirements outlined in the Hazard Communication Standard, 29 CFR 1910.1200 (HCS 2012), are now in alignment with the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

So what has changed and how does it affect me?

Hazard classification: To ensure consistency across manufacturers, the definitions of hazard now provide specific criteria for classification of health/physical hazards and classification of mixtures

Labels: Chemical manufacturers/importers must ensure labeling includes a harmonized signal word, pictogram, hazard statement for each hazard class/category as well as precautionary statements

Safety Data Sheets (SDS) now have a specified 16-section format

Labeling Changes

Labels requirements for shipped containers are more defined and must include:

Product identifier

Signal word

Hazard statement(s)

Pictogram(s) are equired to have red borders regardless of the shipment’s destination. Blank red diamonds are not permitted on the label. Downloadable approved pictograms can be found at https://www.osha.gov/dsg/hazcom/pictograms/index.html

Precautionary statement(s)

Name, address, phone number of responsible party (may be individual’s name or name of department within the company)

Within 6 months of new product information becoming available, all container labels need to be updated according to the HCS 2012 labeling requirements. If you don't comply, prepare to face The Adjustment Bureau (or, rather a government official).

Workplace Containers

For containers used in the workplace, HCS 2012 allows employers to choose to label workplace containers either with the same label required for shipped containers of the chemical, or to use alternative labels, as long as those labels provide employees with general information about the hazards of the chemical, and the employer provides training so that employees exposed to the chemical understand the specific hazards it presents.

Other systems, such as NFPA or HMIS, are permitted for workplace containers. However, the labels have to provide at least general information regarding the hazards of the chemicals. Hazard warnings or pictograms that conflict with the HCS 2012 requirements for the chemical are not allowed on the workplace label.

Training Requirements

According to the rule, employers needed to conduct employee training on the new label elements and safety data sheets format by December 1, 2013.

Label elements

What information is on the new labels and how to use it

Product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and name, address and phone number of the responsible party

General understanding of how the elements interact

Danger means a more severe hazard within a hazard class

Warning is for the less severe hazard

Safety Data Sheet Format

Standardized 16 section format and the type of information they would find in the various sections

It’s important for employers to go beyond general awareness in their employee training programs. Implement procedures to ensure employees are promptly trained on new hazards/substances and routinely review HCS 2012 labels, pictograms and SDS content to increase employee familiarity with the information.…

Compliance Check – The Biggest Challenges

Overall, the biggest challenge with the new requirements is access to updated SDS. Authoring updated SDS, reclassifying chemicals and finding suitable GHS labeling solutions are also impacting compliance progress.

As of December 1, 2015, manufacturers and importers of hazardous chemicals must provide HCS 2012 compliant labels and SDS for every individual container. Existing stock packaged for shipment prior to June 1, 2015 that are HCS 1994-compliant labeled may be shipped without re-labeling. Businesses that repackage/blend/mix hazardous chemicals or distributors of hazardous chemicals must follow the same labeling guidance as manufacturers and importers.

What is Reasonable Diligence & Good Faith and Why is it Important to Me?

In determining compliance with HCS 2012, consideration will be given to what steps were taken to obtain the necessary information through reasonable diligence and good faith, so documentation of efforts is a critical element. Documentation supporting compliance efforts should include:

Oral and written communications directly with the upstream supplier

Efforts to find info through alternative sources

A written account of communications with distributers

Defined course of action to make required changes

Manufacturers or importers should be able to provide a clear timeline when they expect to comply with HCS 2012 to meet the Reasonable Diligence & Good Faith test. Distributors should be able to present documentation of any and all communications with the manufacturer or importer regarding reasons for noncompliance with HCS 2012.

Have questions?

More information on HCS 2012 and its requirements can be found on the OSHA website at https://www.osha.gov/dsg/hazcom/. Or give us a call at (512) 301-1451 and we’ll be happy to assist in answering your questions.

Headline Image by: https://www.flickr.com/photos/albertscherbatsky/

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